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Editor’s Note: Welcome to part 6 in our series about the Resource Conservation and Recovery Act (RCRA). During this series, we’ll guide you through proper hazardous waste handling so you stay compliant and safe.
Facilities that produce hazardous wastes are permitted to accumulate those wastes onsite for a limited amount of time without having to obtain a permit or subjecting the facility to the more stringent requirements of hazardous waste Treatment, Storage and Disposal Facilities (TSDFs). The amount of time that hazardous wastes can be stored onsite without a TSDF permit varies depending upon the facility’s hazardous waste generator status.
Very Small Quantity Generators produce less than or equal to the following volumes of hazardous waste in a calendar month:
To maintain their exemption, the facility must not accumulate greater than 1 kg of acute hazardous waste or 100 kg of any residue or contaminated soil, water or other debris resulting from the cleanup of a spill of acute hazardous waste [40 CFR 262.14(a)(3)]. If the VSQG exceeds these volumes, the waste may be held for no more than 90 days beginning on the date when the accumulated waste exceeded the amounts listed. The facility must follow the Large Quantity Generator requirements for acute hazardous waste and acute hazardous waste spill residues exceeding these limits while the wastes are onsite.
In addition, a VSQG is never permitted to accumulate more than 6,000 kg of non-acute hazardous waste onsite at any time. If the facility accumulates 1,000 kg or more of non-acute hazardous waste onsite, it cannot be held onsite for more than 180 days (or 270 days if it must be transported 200 miles or more) from the date when the accumulated waste exceeded the amount. The facility must follow Small Quantity Generator requirements for all stored non-acute hazardous wastes exceeding 1,000 kg.
A SQG generates the following volumes of hazardous waste per calendar month:
Hazardous wastes may be accumulated for no more than 180 days, unless the waste must be transported 200 miles or more: then the time limit is 270 days [40 CFR 262.16(b)]. Small Quantity Generators of hazardous waste may never accumulate more than 6,000 kg of hazardous waste onsite at any time. They are also subject to emergency preparedness and prevention requirements that include having emergency response equipment and communication systems in place and making arrangements with local first response authorities.
All hazardous waste stored onsite is subject to the following requirements:
A LQG generates the following volumes of hazardous waste per calendar month:
To help avoid the storage of very large quantities of hazardous wastes onsite, LQGs may store their hazardous wastes onsite for no more than 90 days [40 CFR 262.17(a)]. The facility must have emergency procedures in place and conduct personnel training. Wastes must be stored in:
Requiring facilities to properly store and manage hazardous wastes while they are onsite helps to minimize the potential for spills and releases of hazardous wastes into the environment. It also reduces the chance of employee exposure. Facilities who follow these requirements and ship their hazardous wastes offsite within the time limits avoid the more stringent requirements of TSDFs, including additional storage, emergency preparation and permitting regulations.
Up next, we cover the requirements for hazardous waste reporting, including new SGQ requirements. Keep reading at RCRA 101 Part 7: EPA Hazwaste Reporting Requirements.